PPN 010: Procuring steel in government contracts · first published 17 February 2025
PPN 010 updates the government's rules on how central government departments, agencies and non-departmental public bodies (NDPBs) must handle the procurement of steel — whether bought directly or as part of a wider works or services contract. It replaces the previous guidance (PPN 04/23 and PPN 11/16) and brings the language in line with the new Procurement Act 2023, which applies to procurements started on or after 24 February 2025. The core requirement is that contractors on qualifying contracts must collect and pass back detailed data on the steel they use — including how much, what type, and where it came from. This data flows up to the Department for Business and Trade (DBT) via an annual return. The policy explicitly states that buyers must have regard to removing barriers facing small and medium-sized enterprises (SMEs). Other public-sector bodies (e.g. local councils, NHS trusts) are encouraged — but not required — to follow the same best practice.
WHO THIS APPLIES TO
THE ENKII VIEW
For SMEs supplying steel or working on infrastructure contracts where steel is a major component, this PPN creates a clear contractual obligation to track and report steel origin data — and buyers are expected to write that requirement into contract terms and conditions. The explicit duty on buyers to consider SME barriers is an opportunity: SMEs can actively flag disproportionate reporting burdens during market engagement. Wider adoption by other public bodies is encouraged but not mandated, so the immediate compliance pressure falls on central government supply chains only.
1. Set up a system now to record and retain steel origin data at the point of purchase — specifically using the EN10204 Type 3.1 Inspection Certificate — so you can meet the 10-week post-financial-year reporting deadline your main contractor will pass down to you contractually.
SMEs supplying steel or subcontracting on central government construction/infrastructure contracts worth £10m+, or any value where 500+ tonnes of steel is involved — The PPN requires contractors to submit steel quantity, product type, and origin data within 10 weeks after the end of the financial year, and states that an example contract clause will be used to push this obligation down the supply chain.
2. Review any new contract terms and conditions carefully for the steel data reporting clause and make sure your subcontractors and steel suppliers also know they must provide EN10204 Type 3.1 certificates showing melt and pour origin.
SMEs bidding for or already delivering central government contracts where steel is a component — The PPN provides an example clause specifically designed to flow data requirements down to suppliers; if you are a Tier 1 or Tier 2 contractor, you are responsible for collecting and passing this data up to the buyer.
3. During any preliminary market engagement or procurement design phase, formally raise the reporting burden as an SME barrier and ask the buyer to consider proportionate adjustments — the policy explicitly requires buyers to have regard to SME barriers and consider removing or reducing them.
SMEs facing disproportionate administrative burdens from steel reporting requirements on central government contracts — The PPN lists 'a duty to have regard for particular barriers facing SMEs and considering whether such barriers can be removed or reduced' as a key procurement design principle for in-scope organisations.
4. Check whether your buyer has voluntarily adopted this PPN's best practice (they are encouraged to do so) and ask during procurement engagement — if they have, the same data collection and reporting obligations may apply to you even though they are not legally required for those buyers.
SMEs bidding for contracts with local councils, NHS trusts or other non-central-government buyers where steel is involved — The PPN states that 'other public sector contracting authorities are encouraged to consider applying the best practice set out in the PPN,' meaning adoption outside central government is possible and growing.
5. Apply the previous PPN 04/23 rules for any procurement that started before 24 February 2025 — do not assume the new PPN 010 terms apply to those contracts.
SMEs bidding for central government contracts commenced before 24 February 2025 — The PPN is explicit that the Procurement Act 2023 'does not apply to procurements commenced before 24 February 2025' and directs those to PPN 04/23.
Every rule below quotes the official document verbatim.
The PPN applies to all central government departments, their executive agencies and non-departmental public bodies when awarding public contracts where steel is procured directly or indirectly ('relevant steel procurement'), excluding special regime contracts. (All relevant steel procurements, central government, executive agencies, NDPBs)
“This PPN applies to all central government departments, their executive agencies and non-departmental public bodies when awarding public contracts for goods and/or services and/or works, other than special regime contracts, where steel is being procured directly or indirectly ('relevant steel procurement').”
In-scope organisations must apply this PPN from 24 February 2025; it covers procurements commenced on or after that date under the Procurement Act 2023. (All in-scope organisations, procurements commenced on or after 24 February 2025)
“In-scope organisations should note the provisions of this PPN from 24 February 2025.”
Steel origin data reporting applies to projects/programmes with a value of £10 million or more. (In-scope organisations, relevant steel procurements)
“with a value of £10 million or more”
Steel origin data reporting also applies to projects/programmes worth less than £10 million where the project is anticipated to require more than 500 tonnes of steel. (In-scope organisations, relevant steel procurements below £10m but high steel volume)
“a value of less than £10 million where it is anticipated that the project will require in excess of 500 tonnes of steel”
Contractors must submit steel data (quantity, product type, and origin) to the in-scope organisation within 10 weeks after the end of the financial year. (Contractors on qualifying relevant steel procurements)
“The data should be submitted within 10 weeks after the end of the financial year by the contractor to the relevant in-scope organisation.”
Steel origin data must be recorded as set out in the Inspection Certificate (EN10204 Type 3.1), and contractors must indicate whether the stated origin is also recorded as where the steel was melted and poured. (Contractors on qualifying relevant steel procurements)
“The steel origin data should be recorded as set out in the Inspection Certificate (EN10204 Type 3.1) and contractors should indicate whether the origin stated is also recorded in the certificate as where the steel was melted and poured.”
In-scope organisations must provide an annual steel data return to the Department for Business and Trade, covering pipeline data of projected steel requirements and actuals data on steel procured in the previous year. (All in-scope organisations)
“In-scope organisations are already required to provide an annual steel data return to the Department for Business and Trade, which is collated and published on Gov.uk. This consists of (a) pipeline data of projected steel requirements; and (b) actuals data on steel procured in the previous year – including quantity, product type, and origin data.”
Buyers must have regard to particular barriers facing SMEs and consider whether such barriers can be removed or reduced when designing procurements. (All in-scope organisations designing relevant steel procurements)
“ensuring a level playing field for suppliers including a duty to have regard for particular barriers facing SMEs and considering whether such barriers can be removed or reduced”
Other public-sector contracting authorities (e.g. local councils, NHS trusts) are encouraged but not required to apply the best practice in this PPN. (Public sector bodies outside central government — encouraged, not mandated)
“Other public sector contracting authorities are encouraged to consider applying the best practice set out in the PPN and guidance, as appropriate, where they do not have equivalent measures in place.”
An example contract clause is provided to help buyers push steel data reporting requirements down to suppliers through contractual terms and conditions. (In-scope organisations and their contractors)
“An example clause, to help ensure the data requirements are pushed down to suppliers through contractual terms and conditions, is also provided.”
For procurements commenced and contracts awarded before 24 February 2025, the previous PPN 04/23 continues to apply. (In-scope organisations with procurements started before 24 February 2025)
“The Procurement Act 2023 does not apply to procurements commenced before 24 February 2025 or to contracts awarded prior to this date... For procurements commenced and contracts awarded before this date, please refer to PPN 04/23.”
This briefing is enkii's interpretation of the official document — the official text always governs.
Source document © Crown copyright, reused under the Open Government Licence v3.0 via the GOV.UK Content API. enkii tracks every Procurement Policy Note and briefs changes the day they land — see all briefings.